On 1 December 2025, the President of Poland vetoed the Polish Act on the Crypto-Assets Market — the law intended to adopt MiCA in Poland.
To be clear: I welcome this decision. It is fully consistent with the predictions I presented in my earlier MiCA in Poland updates. The veto immediately shifts the regulatory landscape and pushes the Polish market into a new phase. in my view, it creates more potential opportunity than risk.
The veto means that MiCA will not be adopted in Poland in December 2025. It also means that the legislative process has effectively been reset and the future shape of Polish CASP license is open again. Below I explain what happened, what the veto means in practice and why the long-term outlook for the Polish market may actually improve.
Why the President vetoed the Act
According to the President’s official spokesperson, the veto was based on three core concerns:
1. Website-blocking powers
The Act gave government authorities the ability to block CASP websites through a single administrative decision. The President argued that the provision lacked transparency, created potential for abuse and could result in users losing access to their digital assets. He noted that other EU Member States rely on simple warning lists rather than domain-level blocking.
2. Excessive overregulation
While Czechia, Slovakia and Hungary adopted short, technical MiCA-implementing acts, the Polish bill exceeded 100 pages. The President described this as overregulation that could push companies abroad and weaken — rather than strengthen — the domestic crypto market.
3. Supervisory fees harmful to small firms
The planned fees were described as disproportionate and harmful for domestic startups, while favouring large foreign financial institutions. According to the President, this would distort competition and suppress innovation.
The spokesperson emphasised that the President supports regulation of the digital-assets market, but only when it is proportionate, transparent and aligned with MiCA. The veto, according to the statement, was taken “to protect the economic security of Poles.”
Dziś Prezydent Rzeczypospolitej Polskiej podjął decyzję o zawetowaniu ustawy o rynku kryptoaktywów. Prezydent Karol Nawrocki korzysta z konstytucyjnej prerogatywy weta tylko wtedy, kiedy przepisy zagrażają wolnościom Polaków, ich majątkowi i stabilności państwa. A ta ustawa Pokaż więcej
— Rafał Leśkiewicz (@LeskiewiczRafa) 1 grudnia 2025
What the veto means in practice
A veto does not kill the adoption of MiCA in Poland — but it resets it. Several paths are now possible. Below are the most realistic ones.
Scenario 1: A new “MiCA +0” bill
This is the scenario discussed most actively within the industry.
“MiCA +0” means implementing MiCA exactly as written, without gold-plating, without unnecessary national additions and without expanding supervisory powers beyond the European standard.
For the market, this would be the most competitive MiCA implementation in the EU and could position Poland as one of the most attractive jurisdictions for obtaining a CASP licence.
Scenario 2: A slower legislative restart (Q1–Q2 2026)
If political negotiations take time, MiCA adaptation in Poland may be pushed into mid-2026 or later.
Regardless of the scenario, another option appears in the background: creating a new supervisory authority dedicated exclusively to the CASP sector. In my view, this would have been the correct solution from the beginning — but at this stage it is unrealistic. Creating a new regulator would take months. A more pragmatic alternative could be establishing a specialised crypto-focused unit within the KNF. However, still, the KNF will continue to be the Polish CASP supervisor.
Impact on VASPs and CASP applicants
So far, all predictions presented in my earlier analyses have proved correct. And I believe that Poland will eventually attract many small and mid-sized players seeking a fair, transparent and competitive MiCA jurisdiction.
Importantly, the strategic reality for VASPs does not change: building a complete CASP license application still takes time. For most companies, it is 2–4 months of real, substantive work. A legislative delay does not reduce these requirements — it only gives companies more room to prepare properly.
I will continue to monitor progress on MiCA adaptation in Poland and publish actionable guidance. The veto does not stop the process — it simply puts us on the final straight, but on a path that may ultimately be better for the entire industry.
MiCA in Poland updates
MiCA in Poland – new crypto regulations
MiCA in Poland – update August 2024
MiCA in Poland – update December 2024
MiCA in Poland – update January 2025
MiCA in Poland – update March 2025
MiCA in Poland – update May 2025
MiCA in Poland – New act published (May 2025)
MiCA in Poland – update September 2025
MiCA in Poland – update October 2025
MiCA in Poland – update November 2025
MiCA in Poland – update December 2025
